In perhaps the most severe set of penalties that we have seen for public inspection file violations, the FCC released two sets of fines to stations that had self-reported, in their license renewal applications, that they did not have Quarterly Issues Programs lists in their public file for the entire 8 year license term. As we recently wrote, $10,000 fines for missing Quarterly Issues Programs lists have become the new standard where a substantial number of the lists are missing. Here, however, there were no timely filed lists at all in the public files for the stations in question – for an 8 year period. In one case, where the owner had both an AM and an FM stations, both were missing the Quarterly lists, the Commission proposed a fine of $20,000 ($10,000 for each station), and renewed the station licenses for only 4 years, not the normal 8 year license renewal term. A similar fine was proposed for a college-owned noncommercial station, also missing the required Quarterly lists for the entire license period – and that station also received a 4 year license term. In each case, the licensee had indicated that it was doign some renewal-time recreation of missing Quarterly lists, but these efforts did not seem to result in any lessening of the penalties proposed by the FCC. These fines and short-term license renewals show just how importantly the FCC treats these violations.
We do note, however, that where the missing lists are from but a few quarters, the FCC’s fine is somewhat reduced, witness a recent $4000 fine for lists missing for just over a year – where the violations were from the beginning of the license term rather than being of recent vintage. But if you are missing list from some longer period of time – seemingly about 2 years – that $10,000 fine seems to kick in. Check you files now to make sure that you don’t fall into the $10,000 trap.